PRIVACY POLICY

Lotus Clouds is committed to processing data in accordance with its responsibilities under the General Data Protection Regulation 2018 (GDPR).

Article 5 of the GDPR requires that personal data shall be: 

• Processed lawfully, fairly and in a transparent manner in relation to individuals

• Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be incompatible with the initial purposes

• Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed

• Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay

• Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed

• Personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR to safeguard the rights and freedoms of individuals

• Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures

Lawful, fair and transparent processing 

To ensure its processing of data is lawful, fair and transparent, Lotus Clouds will not save or store personal contact information relating to individuals who have participated in any Lotus Clouds classes or workshops beyond a year from the date of joining a session administered and managed by Lotus Clouds. 

Individuals have the right to access their personal data and any such requests made to Lotus Clouds shall be dealt with in a timely manner.

Data minimisation

Lotus Clouds shall ensure that personal data is adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

Accuracy

Lotus Clouds will take reasonable steps to ensure that any personal data is accurate. Where necessary for the lawful basis on which data is processed, steps shall be put in place to ensure that personal data is kept up to date.

Archiving / removal

To ensure that personal data is kept for no longer than necessary, Lotus Clouds will delete any data once an individual has not attended a class for a year or if an individual request this sooner.

Security

Lotus Clouds will ensure that any personal data and data is stored securely.

Access to personal data shall be limited to personnel who need access and appropriate security should be in place to avoid unauthorised sharing of information.

When personal data is deleted this should be done safely such that the data is irrecoverable.

All personal information is stored via paper copies of health and wellness questionnaires. Email addresses are stored electronically.

Breach

In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, Lotus Clouds shall promptly assess the risk to people’s rights and freedoms and if appropriate report this breach to the Information Commissioner's Office (ICO) https://ico.org.uk/

This policy applies to all personal data processed by Lotus Clouds

Bansi Martins (responsible person) shall take responsibility for the ongoing compliance with this policy

This policy shall be reviewed annually

Updated July 2018